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AMROBA keeps up the pressure over regulations + ASRR

AMROBA has kept up the pressure over the problem with regulations [of CASA] with the following notes and a series of very well attanded meetings through out Australia. The last was at Moorabbin, just before Xmas and has released the following on it’s website:

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Maintaining Aviation Safety – New Aircraft/Regulation

What is the difference when an operator introduces a new aircraft type to their fleet and when the government introduces a new regulation?

One would think the same safety approach would be taken so no ‘uncertainty’ would exist for those that operate and maintain the new aircraft and those that have to comply with the new government legislation.

The aviation industry prides itself on its human factors research that has been instrumental in reducing aircraft incidents and accidents. Operators and organisations put into practice processes and procedures to continually improve safety by risk mitigation. So why wouldn’t that knowledge be utilised by government when it introduces new aviation legislative requirements?

After all, safety mitigation is paramount to the continued safe operation of aircraft.

Aviation operators and organisations use safety management systems to manage risks. Safety management systems provide for goal setting, planning, and measuring performance all of which must be available before introducing a new aircraft into service.

For example, if an aircraft operator intends to purchase a new aircraft type, then there are many things that must be planned, financed and implemented before the operator can put the aircraft safely into service.

Once the aircraft type is decided, the operator has to address items, such as, but not limited to, the following:

Obtaining all technical documentation from the aircraft manufacturer applicable to operating and maintaining the aircraft.

Reviewing the operator’s documentation and amending, in many cases amendments are approved by the regulator, to cover the operation and maintenance control of the aircraft.

The operator then has to identify the training needs of their pilots and the maintenance personnel/organisation that will maintain the aircraft.

A flying training program has to be implemented, including intended route procedures training.

Equipment associated with the operation and line servicing of the aircraft has to be obtained and applicable persons trained in the use of same.

Pilot and maintainer skills must all be attained prior to commencement.

The operator must have everything in place before commencing operations.

So why is it different when government (regulation manufacturer) makes a new regulation, with a specified commencement date, but hasn’t produced the documentation to support the new regulation?

How can the operator implement the necessary training, change of procedures, etc and ensure employee proficiency before commencement of the new regulation?

In the first instance, the operator cannot introduce the new aircraft into operation until all the risk elements have been mitigated.

In the second instance, the government set a commencement date irrespective to mitigating the risks with implementing a new regulation.

This is an industry that spends considerable resources in risk mitigation to make flying as safe as possible but will be required to comply with a Commonwealth Regulation when the regulation manufacturer (CASA) has not yet provided the supporting documentation.

CASR Parts 61, 141 & 142 commence on 3rd December 2013.

How can the operator manage the risks when the government (regulation manufacturer) has not provided the documentation that the operator is dependent on to implement the training programs.

So all of the human factor research that this industry prides itself in has been totally ignored by a government that is apparently not being advised by safety specialists in the industry who see this as a high risk approach to safety.

The government should, if aviation is to maintain its high level of risk mitigation as part of operators and organisations safety management systems, remove the risks and not apply the regulation until all training has been carried out.

This should be the approach if government adopted the safety management systems that operators and organisations utilise to manage risks.

Once all the government (CASA) documentation is promulgated, then the government should provide adequate time for those affected in industry to obtain full understanding of the regulations before applying the regulations.

Learning safety is one thing, making it part of the culture is another thing.

This is one organisational element that operators and organisations cannot mitigate the risks involved.